Right Now Right Here Pte. Ltd. (“Now.Here.,” “us” "we" or “our”) is committed to protecting and respecting your personal data in connection with your use of our website located at www.treasure-earth.global (the “Website”) and the Treasure Earth mobile application (the “Application”) (collectively referred to as the “Platforms”). Now.Here supplies content, products or services (collectively referred to as the “Product” or “Products”) listed on the Platforms or via other delivery methods to you. This data policy (“Data Policy”) and any other documents referred to herein set forth the basis on which any personal data we collect from you, or that you provide to us, in connection with the Products will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will collect, use and disclose your personal data. If you have an unresolved privacy or personal data concern that we have not addressed satisfactorily, please contact us at data@now-here.global.

1. GENERAL

In this Data Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified: 

1. from that data; or

2. from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

2. DATA WE MAY COLLECT

We may collect and process the following data about you:

(a) personal data including, for example, your name, e-mail address, password, and in certain instances, telephone number, data about your usage of the Products and data collected by tracking technologies as further described in section 5 below that may identify you as an individual or allow online contact with you as an individual;

for individuals using the Products in connection with a Corporate Community client account as described in Section 7, business data such as your company name, and company email address to the extent that you or your Corporate Community provides such data;

(b) Facebook profile information, such as name, email address, and Facebook ID, if you choose to log in to the Products through Facebook;

(c) device information, such as operating system version, device type, and system performance data; and

(d) data collected via tracking technologies, as fully described in section 5.

All the information required in the open text fields during the account registration process is mandatory. Any failure to complete that information or any response Now.Here. considers abnormal may result in Now.Here. refusing (or being unable) to process your request. 

You agree that the personal data you provide about yourself or subsidiary account holders to Now.Here is current, accurate, complete and unequivocal.

Now.Here. does not collect or process credit or debit card (“Payment Card”) data. Apple and Google collect Payment Card data with respect to in-app purchases made through the Application, and our payment processor collects Payment Card data with respect to purchases made through the Website. Such payment processors generally provide us with some limited data related to you, such as a unique, anonymous token that enables you to make additional purchases using the data they have stored, which include: your card type; expiration date; billing address; and the last four digits of your card number.

3. CONFIDENTIALITY AND SECURITY

The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. However, while no method of electronic storage is fully secure, Now.Here. strives to protect the security of your personal data and we are constantly reviewing and enhancing our security measures in place.

If you have any questions about the security of your personal data, you can contact us at data@now-here.global. Except as described under the “Disclosure of Your Personal Data” section below, we do not provide your personal data to any third party without obtaining your consent, unless required under applicable law.

4. NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS

If you sign up to receive promotional materials from us via email and/or push notifications, we will use your personal data to provide the communications you have requested. If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us at data@now-here.global, we will remove you from our mailing list within 30 business days from the date of making such a request. If you no longer wish to receive push notifications, you may turn them off at the device level. If you provide your phone number to us directly or through a third-party for the specific purpose of receiving an SMS message with a link to our Platforms, you will receive such SMS message (the “SMS Service”). Standard text message rates will apply.

5. TRACKING TECHNOLOGIES

Now.Here. uses technologies such as cookies, beacons, tags, and scripts to enable a service to recognise your device. This allows you to avoid having to provide the same data several times during one task; and enables us to recognise that you may have already given a username and password so you do not need to do it for every web page requested; and for Now.Here to measure how people are using the Products.

We may use local storage, such as HTML5, to store content data and your preferences. Third parties with whom we partner to provide certain features on the Products also use HTML5 to collect and store data. Various browsers may offer their own management tools for removing HTML5.

From time to time, we may partner with third parties, such as Facebook and Google, to manage our advertising of the Products on other sites or platforms as well as across your other devices based on your past visits to our Website. Our third party partners may use technologies such as cookies to gather data about your activities within the Products to deliver such advertising to you, such as retargeting ads. We are not always able to respond to do-not-track signals. For more data about interest-based ads, including how to opt-out of having your web-browsing data used for behavioral advertising purposes, please visit www.aboutads.info/choices. Please note that this does not opt you out of being served ads. You may continue to receive generic ads on these third party platforms. You may also opt out of receiving ads across devices by adjusting your ad preference in your Google account.

We use third party trackers to let us know when users have visited the Products by “clicking-through” our sponsored advertising or content hosted on third party platforms. The Products use Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Products and the volumes of usage of the Products. This is done to ensure that the Products are available when you want them and are fast. For more data on how Google Analytics processes this data, visit www.google.com/analytics.

We will acquire consent from you in order to use such trackers to the extent required by applicable law. For more information on the types of cookies used by Now.Here. and your ability to restrict the behavior of cookies or disable them in your browser’s settings, please refer to the Now.Here. Cookie Policy.

MOBILE ANALYTICS

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record data such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.

LOG FILES

As true of most websites, we gather certain data and automatically and store it in log files. This data may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.

6. WHERE WE STORE YOUR PERSONAL DATA

All personal data you provide to us through the Products is stored on our secure servers located in Singapore. 

Unfortunately, the transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to the Products and any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

7. CORPORATE AND OTHER COMMUNITY SHARING

Now.Here. is also offered through partnerships with organisations. Sometimes corporations, governments, hospitals, universities and other organisations and groups (“Partners” or “Partners”) wish to make Now.Here. available to their members, employees and their families, patients, customers, residents or others. For example, employers may offer their employees and their families access to Now.Here., and brands that promote wellness may wish to and do offer Now.Here. through their loyalty programs. When an entity provides access to Now.Here. to others, we call this a “Corporate Community.” If you have registered to use the Products through a code, credential, or other means of registration furnished by a Partner (a “Corporate Community Subscription”), the Partner may have access to your name, email address, the date you registered to use the Products, and the date on which you last used the Products. The Partner may also have access to your Corporate Community's aggregated and anonymised general usage data.

8. SINGLE SIGN-ON

You may be able to log-in to our Products using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal data (such as your name and email address) with us, and to pre-populate our sign-up form. Services like Facebook Connect give you the option to post data about your activities on our Products or to your profile page to share with others within your network.

9. YOUR DATA RIGHTS

Under the Personal Data Protection Act (“PDPA”) in Singapore, individuals have certain rights in relation to their personal data. Under this law, individuals have a right to (i) obtain access to your personal data within our possession or control, and to (ii) obtain information on how such personal data was used or disclosed in the preceding 12 months.  

A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you that we may have in our possession or control. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

To exercise one or more of these rights, you can email our Data Protection Officer at data@now-here.global. will respond to your request in a reasonable timeframe and in accordance with applicable laws. If we are unable to respond to your request within 30 days, we will also write to inform you of this.  

10. PURPOSES FOR COLLECTION AND USE OF THE DATA

We use your personal data  for any or all of the following purposes:

(a) To provide you with the Products.

(b) To answer your questions or requests for information or handle your complaints.

(c) To ensure that content provided by the Products is presented in the most effective manner for you and for your computer or other device.

(d) To provide you with promotional communications, such as emails, to the extent that you have provided consent to receive such communications under applicable law.

(e) To carry out our obligations arising from any agreements entered into between you and us.

(f) To allow you to participate in interactive features of the Products, when you choose to do so.

(g) To notify you about updates or changes to Product features and content.

(h) To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as post code, state or country).

(i) To account for applicable sales taxes based on zip codes provided to our payment processors for purchases made through the Website.

(j) To inform Partners about your registration and use of the Products as described under Corporate and Other Community Sharing in Section 7 above.

(k) To serve our advertisements to you through third party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent for such uses under applicable law.

(l) To provide you with the SMS Service to the extent that you have provided consent for such practices under applicable law.

(m) We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

(n) To manage your payments and orders.

(o) If you are an existing customer, we will only contact you by electronic means (e-mail or in-Product communication) with information about products and services similar to those which were the subject of a previous sale to you, except if you opt-out to such communications.

11. DISCLOSURE OF YOUR DATA

We may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may also disclose your personal data to third parties as follows:

(a) In some circumstances, based on your specific requests, we may need to disclose your personal data to a third party so that it can provide a service you have requested from such party, or fulfill a request for data from such party. An example of this is the SMS Service.

(b) In some circumstances, we may disclose the personal data that you have provided to Now.Here. to a third party that offers and/or provides goods or services complementary to our own for the purpose of enhancing our users’ experiences by offering you integrated or complementary functionality, complementary services or bundled pricing options.

(c) If Now.Here.’s service providers (like hosting, IT maintenance, market analytics, and payment service providers) require this data to provide services to Now.Here. Now.Here. requires each of its service providers to agree to maintain the confidentiality and security of your personal data.

(d) In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

(e) If Now.Here. or substantially all of our assets are acquired by a third party, in which case the personal data held by us about our customers will be one of the transferred assets.

(f) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation such as to comply with a court order, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of Now.Here., our customers, or others. This includes exchanging data with other companies and organisations for the purposes of fraud protection and credit risk reduction.

(g) With your Community, if your subscription is a Community Subscription, as described under Corporate and Other Community Sharing above.

(h) With third parties, such as Facebook, in order to serve Now.Here. advertisements on such third party platforms, to the extent that you have consented to such practices under applicable law.

(i) If you choose to have your account verified to confirm your status as a student, we may allow a third party platform to access the specific personal data you provide in order to perform the verification.

(j) If you chose to have your account verified to confirm your status as a US-based healthcare provider, we may collect your National Provider Identifier (“NPI”) in connection with your email address in order to perform the verification.

12. DATA RETENTION

The retention periods applied by Now.Here. comply with applicable legislation in effect on the date hereof, namely:

For data relating to your account: such data will be permanently and irrevocably anonymised in the event that your account is: (i) inactive for a period of two (2) years; and (2) not subscribed to “Treasure Earth Premium.” Moreover, we will permanently and irrevocably anonymise your account data within thirty (30) days of your written request to do so via email to data@now-here.global.

For transactional data relating to your purchases: such data is kept for the entire period of the contractual relationship, and thereafter if retention is necessary for legal or business purposes. Please note that this data does not include Payment Card information, which is processed by our third-party payment processors, and not Now.Here.

For data collected based on your consent to receive our marketing communications: we will use such data until you withdraw your consent to such use, or if it is no longer necessary for any business or legal purposes.

When your data is collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.

When cookies or other trackers are placed on your terminal, they are kept for a period of 12 months. Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.

13. WITHDRAWAL OF CONSENT

If you had previously provided consent for the collection and use of your personal data, you may withdraw such consent at any time by emailing our DPO at data@now-here.global. 

14. LINKS TO THIRD PARTY SITES

The Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own data or privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.

15. SOCIAL MEDIA WIDGETS

Our Products include social media features, such as the Facebook Like button, and widgets, such as the “Share This” button, or interactive mini-programs. These features may collect your Internet protocol address, which page you are visiting on or Products, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Products. Your interactions with these features are governed by the data statement of the company providing it.

16. HEALTHKIT

Apple iOS users may opt-in to allow the Products to provide data regarding the amount of minutes meditated to the Apple iOS “Health” application for display. This data will not be shared with third parties or used for marketing purposes.

17. USE OF TREASURE EARTH BY MINORS

You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilise the Products only with the consent of a parent or legal guardian under such person's account.

18. CHANGES TO OUR DATA POLICY

We may update this Data Policy to reflect changes to our data practices. If we make any material changes we will notify you by in-Product message, email (sent to the e-mail address specified in your account) or by means of a notice in the Products prior to the change becoming effective. We encourage you to periodically review this page for the latest data on our privacy practices.

19. CONTACT AND EEA REGISTERED AGENT

Questions, comments and requests regarding this data policy are welcomed and should be addressed to Now.Here’s Data Protection Officer at data@now-here.global.

Any correspondence to the DPO may also be addressed to Now.Here.’s office address at:

Right Now Right Here Pte. Ltd.
43A Beach Road #02-00 
Singapore 189681
Attn: Data Protection Officer

20. TRANSMISSION TO OTHER COUNTRIES

The subsidiaries, service providers or other third parties listed above to whom Now.Here. may disclose your personal data to may be domiciled outside Singapore.

In such cases, Now.Here. will require them to take, in accordance with applicable legislation, contractual, organisational and technical measures designed to ensure an adequate level of protection of your personal data, and at a level comparable to that required under the PDPA. 

While Now.Here. strives to ensure that your personal data is protected after it has been transferred to other countries, Now.Here is not to be held liable if the third parties listed above fail to implement reasonable measures to protect your personal data. 

It is an honor and privilege to help you connect with nature and be a happier, more compassionate and eco-friendly person.